What binds on an election form?

The following is a more detailed summary of a case about which I have written previously.

In R & S Industries Inc. v R, 2017 TCC 75, the Court held that the CRA and the taxpayers who file an election under s 85 or s 97 were bound by the agreed amounts set out in the election form (subject to the limits on agreed amounts set out in s 85). The Court, however, held that neither the CRA nor the taxpayers were bound by the other “key facts” set out on the form.